Continue lighweighting efforts
Improve regulations for refillable containers and deposit return systems
Carry through on banning consumer single use plastics
Require large chain retailers to give out reuseable materials
Research on refillable farm and processing containers
Regulate packaging shapes to ensure all food can be extracted
Regulate terminology and permitted composition for biomaterial plastics
Eliminate packaging that is associated primarily with branding
Improve training in food packaging design
Improve and extend Circular Economy, Waste - free legislation
Government procurement programs
Continue lighweighting efforts
Many companies have been successfully reconfiguring their packaging across a wide range of materials as a cost and logistics efficiency and environmental improvement measure, known as lighweighting. These efforts sometimes involved changes to materials or material manufacturing to reduce weight and improve strength and durability (Marsh and Bugusu, 2007). MacRae et al. (2013) summarize the efforts of a cereal company that changed secondary packaging to fit better in trucks and increase product volume / shipment while reducing energy use and GHG emissions. The Canadian Produce Marketing Association put out guidelines for the industry in 2022 to reduce packaging, swap out problematic materials and reducing virgin plastic use.
Lightweighting is not without its challenges for certain materials. Glass, for example, can only be so thin before the possibility of breakage is enhanced. Foils and laminates, already thin, can only be reduced in thickness so much before their functionality is compromised (Marsh and Bugusu, 2007). This has caused some difficulty in Europe where some of EPR fees have encouraged lightweighting but resulted in materials that have low reuse/recycle rates. This requires caution when setting fees (see Substitution and Watkins et al., 2017).
Obviously, lightweighting should not result in greater food waste and there are many examples of lightweighting increasing shelf life, but there may be situations in which legitimately more secondary and tertiary packaging may be required to reduce food waste associated with transport. This is particularly important when the negative impacts of food waste far exceed the negative impacts of the packaging. It may also be feasible to use plastic more for lightweighting in secondary and tertiary using plastics with high recycled content. (NZWC, 2020).
These efforts by companies should continue, although the pace of improvements will likely slow based on the inherent limitations of the materials.The benefits for firms are usually apparent in traditional bottom line calculations and the other measures proposed here will likely also contribute to savings.
Improve regulations for refillable containers and deposit return systems
Rules are provincial/territorial and vary tremendously across the country (Bottle Bill Resource Guide). Not all refillable containers are covered, deposit rates vary alot and the collection happens in a variety of ways. Only some provinces require return to retail. Some are primarily industry sponsored, others have more active engagement of government or paragovernmental agencies. All this results in wildly different return rates for different containers. Many programs focus excessively on recycling rather than first maximizing return/refillable possibilities before recycling options kick in. A wide range of regulatory instruments are applied, with different legal frameworks (e.g., litter vs. EPR). Most provinces, with the exception of BC and MB, still use a product stewardship approach, whereby funding is provided primarily by consumers and taxpayers, not producers (Arnold, 2019).
The Canadian Council of Ministers of the Environment (CCME) must discuss and create a comprehensive and relatively consistent national effort to improve refillable containers already in use. At the substitution stage, instruments can be put in place to shift to more refiillable containers from recylcables, but here, the system must:
- set targets with progressive improvements in return rates and refill rates; must cover alcoholic and non-alcoholic beverages, including milk and milk substitutes; penalties for non-compliance should be set and enforced.
- have a regulatory foundation that does not rely primarily on industry efforts; as such, the regulations and programs can be shifted to Zero Waste legislation (see below);
- must include depots and retailers, and can allow exemptions for SME retailers who do not have sufficient storage facilities (note that many SME alternative retailers already do deposit return); as part of this, big chain grocery stores should have to implement deposit return systems for beverage containers.
- deposit-refund systems must be applied to alcoholic and non-alcoholic containers as these systems increase return / reuse rates (Arnold, 2019) and rates must include a fee for the depot/retailer and for the consumer; rates should reflect the importance of returning/refilling the container; recipients of refillable containers must allow contribute to program expenses
- should not permit refillables in curbside recycling programs
Carry through on banning consumer single use plastics
The pandemic has resulted in significant curtailing of food retailer refillable programs, and more people have been using single use plastics in the hope of containing spread of the virus (CBC, 2020). The federal government has announced a ban on specified single-use plastic products and packaging (see Current Government Initiatives) implemented in 2022 under the Canadian Environmental Protection Act (Government of Canada 2019; ECCC, 2020). The regulations cover the manufacture, import and sale of 6 categories of single use plastics: checkout bags, some foodservice ware, cutlery, ring carriers, stir sticks and straws. Implementation will occur between 2022 and 2025. Not all single use plastics will be covered in the ban, exempting garbage bags, milk bags, snack food wrappers, and beverage containers and lids. The draft Scientific Assessment of Plastics did not clearly articulate whether single use plastics derived from biological sources might receive different treatment than those derived from fossil fuels (Cocker, 2020). This is an important question, and other proposals in this section could be applied to the single use materials not subject to the ban, including whether only bio-based single use versions of this materials would be permitted. A ban alone is insufficient to generate suitable changes which is why many initiatives are proposed in this section.
Some municipalities in Canada have executed (sometimes suspended during the pandemic) a ban on some single-use plastics while awaiting federal rules (e.g. Vancouver for foam cups, takeout containers, utensils, plastic straws) sometimes with specific exemptions, and use upon request, especially related to barriers. But such initiatives are highly variable in design and coverage. Clearly, a national approach is required and the federal program is necessary. Key issues yet to be resolved are enforcement (almost always weak in Canada), and the timeline for progressively add currently exempt materials and situations that are not related to issues of customer ability to consume. The regulations also permit export of these materials, which should also be forbidden.
Require large chain retailers and chain food service to give out reuseable materials
A ban can be facilitated by ensuring that everyone has access to reusable materials. But to shift the burden partially off individual consumers who in the current environment bear much of the costs of reusable materials, regulations must be imposed so that the big 5 retailers (Loblaw, Metro, Sobey, Costco, Walmart) distribute reuseable materials (bags, utensils, containers, etc) free of charge to households and manufacturers shift their packaging to make it more reusable. Many stores, usually independents with environmental commitments, already provide materials. Some quick service restaurants and retailers in Canada have signed onto the Loop program of Terracycle. A deposit return system, it is being piloted in several locations. Another private firm, Friendlier, is working with retailers to wash refillable containers. The problem is that it requires a new infrastructure that is separate from current waste management initiatives, and if successful, is likely to trigger competing private sector systems, all of which will take considerable resources. IGA has signed up with Reusables.com to provide metal containers instead of single use ones. A unified regulated approach that is mandatory across all large food system chains is required otherwise a chaotic patchwork of private sector initiatives will result. This should be required as part of EPR implementation and Waste-free legislation (see below). An additional feature is that the big 5 chain companies have to pay the government a fee for every single use item sold. Such measures are used in some European jurisdictions to supplement bans (Xanthos and Walker, 2017). Regulations to these effect can be part of Waste-free legislation (see below).
There is, however, some evidence that multi-use plastic bags are also now pollutants because some consumers keep buying them and then dispose of them rather than re-use. A unified database of recipients is required to minimize giving them out over and over again to the same households and after a specified number of issues, people would have to pay for them. All this needs a social marketing campaign financed by the big 5 retailers, as part of EPR obligations.
Research on refillable farm and processing containers
Cleanfarms.ca, a Producer Responsibility collaboration with support from provincial governments, has done a very good job of recycling many types of input and farm packaging (see their annual reports for rates). Quebec, with the Clean Farm system not as well developed as other provinces, is probably the weakest province for farm waste recycling (Sucar, 2019). However, as with most Product Stewardship approaches, there is little incentive in this system for packaging and system redesign, especially the development of refillable, reusable packaging. Similarly, there are few incentives for processors to use reuseable / refillable containers.
A small and growing market exists for such containers (see Leblanc, 2016). There can obviously be issues regarding food safety and cleaning of reuseable containers, and at this stage, what's needed are some specific research programs to clearly identify suitable protocols and material designs, and supportive regulations, to minimize such risks and excessive water and cleaning product use. In the longer-term, circular economy and EPR adoption will make the market for and use of such containers more feasible.
Regulate packaging shapes to ensure all food can be extracted
In the effort to facilitate marketing and convenience, many packaging designs now facilitate food waste because it is difficult to get all the food out. This is particularly a problem with many condiments that used to be provided in pots but are now commonly sold in squeezable bottles with narrow necks. Packaging contaminated with food waste often will not be recycled. Changes are needed to the Safe Food for Canadians regulations to impose design standards for environmental performance and food waste minimization, action that would facilitate a shift away from squeezables and other containers.
Regulate terminology and permitted composition for biomaterial plastics
Many packaging materials are identified as biodegradable, or for example, bioplastics, but the terminology is confusing and inconsistent. Some biodegradable packaging still contain microplastics that can take hundreds of years to biodegrade completely. Others are biochemically comparable to the fossil fuel version, but the source material is plant-derived. However, the degradation pathway is largely the same, and the fossil-fuel derived material can be labelled biodegradable (Chung, 2020). Biodegradable sometimes doesn't mean compostable. And municipal waste management systems can't necessarily handle all these materials so they are treated like regular non-biodegradable packaging (NZWC, 2020). Some biodegradable materials, especially for fast food, contain toxic chemicals (Schwartz - Narbonne, 2023) which should not be permitted.
Canada does not have clear rules on these terms, let alone regulate their composition, except as it relates to food safety matters. A more specific regulation of terms sets the stage for shifting more plastic production to plastics derived from organic waste materials, a longer term transition. There is evidence that some corn-derived plastics have significantly lower GHG emissions than fossil-fuel derived plastics, even when the corn is conventionally produced (cf. Yu and Chen, 2008). Net emissions from organic wastes produced from regionally grown and processed sustainable production may be even lower, as long as the products aren't imported over long distances. The very significant caveat to all this is that we can not convert large swaths of natural landscapes to agriculture to produce biomaterials, so such measures only make sense as part of a significant overall reduction in demand for plastic packaging (see Goal 5, Sustainable Bioproducts).
Regulating terms and product composition would likely have to occur under the provisions of the Competition Act and the Safe Food for Canadians Act (since it incorporates provisions of the former Consumer Packaging and Labeling Act). Under the Competition Act, environmental claims must be supported by adequate and proper tests, otherwise the claims can be viewed as false, misleading or anti-competitive. The Competition Bureau Guidance Document on environmental claims does require Life Cycle Analysis where appropriate (as it would be in this case) and appears to support claims that are verified by third party protocols and verification systems. There is some general language on terms such as compostable and degradable, and this is supported by the Canadian Standards Association (CSA) technical document, CAN/CSA‑ISO 14021, Environmental Labels and Declarations. Given this hierarchy of authority and technical advice, it is in the CSA document that more specific language must be developed regarding use of these terms. Then, the provisions of the Competition Act can be used for enforcement. CSA document development and revision are subject to specific rules which should be applied in this case.
Eliminate packaging that is associated primarily with branding
A significant amount of packaging exists primarily for branding purposes. In fact, many marketing and packaging firms promote the idea that the packaging is the most important way to convey brand identity and values. As a result, they promote "innovation" primarily for its identity purposes, not for its functionality, both food safety and environmental. All this has emerged, in part, because there are too many "copycat" products on the shelf that are essentially the same nutritionally, so brand identity becomes critical in such a crowded and nutritionally undifferentiated market. But this kind of packaging diversity contributes to the resource consumption problem (manufacturing a wide array of shapes and sizes, less dense packing arrangements that increase transport emissions), and can also affect municipal recycling programs (e.g., opaque PET bottles are often confused with other types of plastic and create contamination problems). In addition to a diversity of shapes and sizes, common materials that are primarily for branding purposes include stickers, plastic and paper wraps and covers, ribbons and cords with paper attachments, boxes over bottles, opaque PET, and different inks and textures.
The federal government should make changes to the Safe Food for Canadians Regulations to restrict use of these materials for branding. It also means that the packaging pre-approval process that existed prior to 2014 (see Jurisdiction) should be brought back into use.
Improve training in food packaging design
Many colleges offer diplomas in packaging design, some of which provide specific courses on food packaging. There are also many online and short course offerings specific to food packaging. Most of these Canadian programs appear to preference either graphic design or food safety, both important, but there's little in the public recruitment of students that suggests sustainability is a priority.
There are also short courses on sustainable packaging (e.g., Sustainable Packaging Coalition), but these themes do not appear to be well integrated into existing course offerings.
Improve and extend Circular Economy, Waste - free legislation
It's clear that Canada is substantially behind countries in the EU regarding Circular Economy implementation (cf. European Commission, 2015, 2018; Delphi Group, 2017). Although most provinces and territories have made circular economy commitments, the policy and legislative frameworks for implementation are only weakly in place, which of course means that concrete implementation is even further away. Of particular note is the focus on sustainable food system change in several leading circular economy countries in the EU, including Scotland and the Netherlands (Delphi Group 2017), something that is very absent from Canadian discussions.
Ontario is the only province with a legislative framework for a circular economy. Although far from perfect, and with implementation still unfolding and contested (see Gray, 2020), it sets out processes for transitioning the traditional linear waste diversion approach to a circular economy, with EPR and sector by sector plans (Cairns et al., 2018). All provinces should implement comparable legislation with a particular emphasis on legislative language to support:
- improved EPR implementation, with transition from municipally - driven and Producer Stewardship models (see also Substitution for the next phase of EPR implementation);
- provincial sales tax reductions on goods that can legitimately be considered products of a circular economy, including re-used goods or goods made primarily from recycled materials;
- elevated fees for landfilling and bans on organics (see Goal 5, Food Waste Reduction);
- requirements for sector specific strategies, including the food system (beyond just agriculture)
- government investments in circular economy infrastructure
- changes to public procurement to encourage purchasing of circular economy goods (see below)
Cairns et al. (2018) set out numerous international examples of regulatory models and language that can be employed.
Government procurement programs
Many food companies are changing their vendor rules regarding packaging (cf. NZWC, 2020) and governments must do the same.
As discussed in many parts of this site, procurement can be a driver of market changes. But given competing procurement priorities, it makes sense for this to be a targeted undertaking, involving specified food products in specified food service environments. For example, many government cafeterias and facilities serve pasta and pasta has been identified as a strong candidate for bulk distribution. Government facilities could also be reconfigured, as some have done already, to significantly reduce single use packaging, including utensils, coffee creamers and beverage distribution systems. Procurement could also boost development of biomaterial development, by preferentially purchasing from companies using biomaterials. Procurement is also discussed under Goal 1, Economic Development.
